Comment by: Alan Dixon
Focus area: Chemicals
Regulator concerned: Environment Agency,Health and Safety Executive (HSE)
In general , our experience of COMAH regulation and enforcement has been satisfactory. The appraisals have been generally fair and reasonable.
We have a good working relationship with our general inspectors from the CA, who have been fair in both planned interventions and incident investigations.
Some of the specialist inspectors have been particularly helpful with their constructive criticism, which has prompted us to raise our game in certain areas.
There have been isolated examples of specialists who we felt were unduly over-critical and strayed from the inspection agenda.
The last COMAH Report assessment process and request for further information (back in 2007) was reasonably made and relatively straightforward for us to meet.
Our early experience of the revised COMAH enforcement framework has been positive. We welcome the 2-year intervention plans which give us advance notice of inspection topics. We also welcome the COMAH Report 5-year review planning meetings with the CA, which make for a far more organised and clear approach to the review process.